Privacy Policy

STONETURN GROUP, LLP PRIVACY SHIELD POLICY

StoneTurn Group, LLP and its United States and United Kingdom affiliates (“StoneTurn”) comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Economic Area (“EEA”) to the United States. StoneTurn has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit: https://www.privacyshield.gov/. This Notice only applies to Personal Data within the scope of the StoneTurn U.S. Firms’ Privacy Shield certification.

StoneTurn respects individual privacy and values the confidences of its customers, employees, consumers, business partners and others. Not only does StoneTurn strive to collect, use and disclose Personal Data in a manner consistent with the laws of countries in which it does business, it also has a tradition of upholding the highest ethical standards in its business practices. This Privacy Shield Policy sets forth the principles that StoneTurn follows with respect to transfers of Personal Data from the EEA to the United States.

Scope and Responsibility

Our Privacy Shield certification covers Personal Data regarding:

Current, former, and prospective partners, principals, and employees (collectively “Personnel”) in connection with the Personnel relationship;

Personal Data regarding clients and their personnel and customers in connection with the client relationship, such as the delivery of professional services and the administration of the client relationship; and

Personal Data regarding third parties (such as service providers and contractors) and their personnel in connection with the management and administration of the business relationships with such third parties. Our certification does not cover any disclosure of an individual’s Personal Data to a third party who processes personally identifiable information for its own purposes when the disclosure is made at the request of the individual.

All employees of StoneTurn that have access in the U.S. to Personal Data covered by this Privacy Shield Policy are responsible for conducting themselves in accordance with this Privacy Shield Policy. Adherence by StoneTurn to this Privacy Shield Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this Privacy Shield Policy shall not be collected, used, or disclosed in a manner contrary to this policy without the prior written permission of StoneTurn’s Chief Privacy Officer.

StoneTurn employees responsible for engaging third parties to which Personal Data covered by this Privacy Shield Policy will be transferred are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of this Privacy Shield Principles, including any applicable contractual assurances required by Privacy Shield.

Definitions

“Agent” means a third party that processes or analyzes Personal Data on behalf of StoneTurn.

“Data Subject” means the individual to whom any given Personal Data covered by this Privacy Shield Policy refers.

“Personal Data” means any information relating to an individual residing in the European Union and Switzerland that can be used to identify that individual either on its own or in combination with other readily available data.

Privacy Shield Principles

StoneTurn commits to subject to the Privacy Shields’ Principles all Personal Data received by StoneTurn in the U.S. from European Union member countries and Switzerland in reliance on the respective Privacy Shield framework.

Notice

StoneTurn notifies Data Subjects covered by this Privacy Shield Policy about its data practices regarding Personal Data received by StoneTurn in the U.S. from the EEA in reliance on the respective Privacy Shield framework, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that StoneTurn offers for limiting its use and disclosure of such Personal Data, how StoneTurn’s obligations under the Privacy Shield are enforced, and how Data Subjects can contact StoneTurn with any inquiries or complaints.

Choice

If Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, StoneTurn will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: USPrivacyShield@Stoneturn.com.

If Sensitive Personal Data covered by this Privacy Shield Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, StoneTurn will obtain the Data Subject’s explicit consent prior to such use or disclosure.

Accountability for Onward Transfer

In the event we transfer Personal Data covered by this Privacy Shield Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If StoneTurn has knowledge that a third party acting as a controller is processing Personal Data covered by this Privacy Shield Policy in a way that is contrary to the Privacy Shield Principles, StoneTurn will take reasonable steps to prevent or stop such processing.

With respect to our Agents, we will transfer only the Personal Data covered by this Privacy Shield Policy needed for an Agent to deliver to StoneTurn the requested product or service. Furthermore, we will (i) permit the Agent to process such Personal Data only for limited and specified purposes; (ii) require the Agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles; (iii) take reasonable and appropriate steps to ensure that the Agent effectively processes the Personal Data transferred in a manner consistent with StoneTurn’s obligations under the Privacy Shield Principles; and (iv) require the Agent to notify StoneTurn if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an Agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

StoneTurn remains liable under the Privacy Shield Principles if an Agent processes Personal Data covered by this Privacy Shield Policy in a manner inconsistent with the Principles, except where StoneTurn is not responsible for the event giving rise to the damage.

Security

StoneTurn takes reasonable and appropriate measures to protect Personal Data covered by this Privacy Shield Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

Data Integrity and Purpose Limitation

StoneTurn limits the collection of Personal Data covered by this Privacy Shield Policy to information that is relevant for the purposes of processing or analysis. StoneTurn does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.

StoneTurn takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. StoneTurn takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes StoneTurn’s obligations to comply with professional standards, StoneTurn’s business purposes and unless a longer retention period is permitted by law, and it adheres to the Privacy Shield Principles for as long as it retains such Personal Data.

Access

Data Subjects whose Personal Data is covered by this Privacy Shield Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the Privacy Shield Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to: USPrivacyShield@Stoneturn.com.

Recourse, Enforcement, and Liability

StoneTurn’s participation in the EU-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission. StoneTurn further commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. Data Subjects with inquiries or complaints regarding this Privacy Shield Policy should first contact StoneTurn at: USPrivacyShield@Stoneturn.com.

If the investigation and resolution of complaints cannot be resolved between StoneTurn and the complainant, StoneTurn commits to the following dispute resolution mechanisms of:

For HR Personal Data, a panel established by the Data Protection Authorities of the EU Member State where the Data Subject works; or

For non-HR Personal Data, the JAMS Privacy Shield Dispute Resolution Procedure (contact information is available at https://www.jamsadr.com). The services of JAMS are provided to you at no cost.

As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

StoneTurn agrees to periodically review and verify its compliance with the Privacy Shield Principles, and to remedy any issues arising out of failure to comply with the Privacy Shield Principles. StoneTurn acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of Privacy Shield participants.

Changes to this Privacy Shield Policy

This Privacy Shield Policy may be amended from time to time consistent with the requirements of the Privacy Shield. Appropriate notice regarding such amendments will be given.

Questions Relating to this Privacy Shield Policy

Any questions or complaints concerning our Privacy Shield compliance, or requests to access, correct, amend, delete, or limit the use or disclosure of Personal Data (opt out) may be directed to USPrivacyShield@Stoneturn.com.